FNB Language Policy In Terms of the National Credit Act, 34 of 2005
1 INTRODUCTION This document sets out the language policy for First National Bank, a division of FirstRand Bank Limited, a registered Credit Provider (NCRCP20)( FNB ) as required in terms of Section 63 of the National Credit Act, 34 of 2005 ( The Act ). Section 63(1) determines that a consumer has a right to receive any document that is required in terms of this Act in an official language that the consumer reads or understands, to the extent that is reasonable having regard to usage, practicality, expense, regional circumstances and the balance of the needs and preferences of the population ordinarily served by the person required to deliver that document. 2 CONSUMER SEGMENT BACKGOUND In FNB, the Consumer Segment is impacted by the National Credit Act and caters to the consumer market of the South African banking population with an income of up to R349 999 and supplies credit in relation to small, intermediate and large credit agreements. FNB s customer base and the products we offer to our customers in this segment that are impacted by the National Credit Act are the following: FNB Loans: Personal Loans SmartSpend Loan Student Loan Smart Housing Plan Value Banking Solutions: Overdraft Revolving Loan Temp Loan FNB Card: Consumer Credit Cards: FNB: o Classic o Gold Standalone Petro Joint Venture Credit Cards: Clicks Gold Kulula Discovery Gold 2
Home Loans & Affordable Housing: Variable Rate Mortgage bond Fixed Rate Mortgage bond Advances Re-advances eg, second bond The biggest percentage of the FNB customer base is made up of customers falling within the Consumer Segment and therefore the proposed languages will accommodate this market. CUSTOMER PROFILE In determining this FNB has assessed the practicality, expense, regional circumstances and the balance of the needs and preferences of the population of these customers by considering the previous requests across all 9 provinces for documents in the other official languages. Statistics indicate that there were very little requests for different languages which never exceed 1%. As a result of understanding our market and the requirements of our clients this policy has been updated to cater for the following languages where our statistics have shown a definite customer need, namely: English, Afrikaans, isizulu or Setswana. These changes have been proposed in order to accommodate for the mass market, which is the largest percentage of customers in terms of demographic analysis. In addition, we propose these languages in order to achieve conformity across all business units, to eradicate the risk of providing inferior customer service and to cater for provision of multiple languages that are not being utilized and to simplify the processes in terms of new product development. 3 FNB CONSUMER SEGMENT LANGUAGE POLICY AND DOCUMENTATION In accordance with section 63(2) of the Act, FNB will provide consumer support and documentation across varying consumer segments as set out below while striving to ensure that customers receive verbal and written communication in an official language and in plain language. FNB employees are instructed to ensure that the customer understands the information received from the bank: 3.1 All documents required by the Act are drafted in English. 3.2 Quotation, Pre-Agreement Statement and the summary of the consumer s rights and obligations: The English version of the Quotation, Pre-Agreement Statement and the Credit Agreement will be the legally binding contract between the consumer and FNB. FNB will make the Quotation, Pre Agreement Statement, and a summary of the consumer s rights and obligations, pertaining to Small and Intermediate Credit Agreements, available in English, Afrikaans, isizulu and Setswana. FNB will make the Pre-Agreement Statement, and a summary of the consumer s rights and obligations, 3
pertaining to Large Credit Agreements namely the products as listed above under Home Loans & Affordable Housing, available in English, Afrikaans, isizulu or Setswana. 3.3 Section 129(1)(a) and Section 86(10) notice: The Key Information documents (which include the quotation and consumer s rights and obligations) and enforcement documents (section 83(10) and section 129(a)) be translated in Afrikaans, isizulu and Setswana upon request of the customer. 4. Delivery Channels (Points of Contact With The Customer) 4.1 Call Centres: The servicing call centre within FNB will have the capability to converse with the consumers in English, Afrikaans, isizulu, Setswana. All credit sales executed through calls and maintained as voice recorded Quotations; Pre Agreement Statements and Credit Agreements, will be recorded in English. Upon the consumer s request FNB will explain the Quotation, Pre-agreement Statement and Consumer s rights and obligations in Afrikaans, isizulu and Setswana. Alternatively, FNB will make the aforementioned documents available to the consumer in the consumer s preferred language from the options stated above. The voice recording will be transcribed into Afrikaans, isizulu and Setswana as per the consumer s request and made available to the consumer. 4.2 Branches FNB branches will render services to consumers in English, Afrikaans, isizulu and Setswana as per the consumer s preference. 4
4.3 Internet, Banking App, Online Banking and ATM: The content on FNB S website (www.fnb.co.za), ATMs and online banking is published in English. However, should a consumer request the Quotation; Pre- Agreements Statement; and the summary of the consumer s rights and obligations in Afrikaans, isizulu and Setswana same will be made available by FNB. 4.4 Telephone and Cellular Phone Banking: FNB s telephone and cellular phone banking service are available in English and Afrikaans. Should the consumer request the Quotation; Pre Agreement Statement; and a summary of the consumer s rights and obligations in Afrikaans, isizulu and Setswana same will be made available by FNB. 5. MARKETING AND ADVERTISING The marketing and advertising of credit products in any media type, other than bill boards, will be provided in the language of the actual media. For billboards marketing and advertising of credit products will be provided mainly in English. Product brochures in branches are printed in English only. Upon a customer request an electronic version of the brochure will be printed by a service consultant in either Afrikaans, isizulu or Setswana 6. PREMIER BANKING PRODUCTS AND BUSINESS BANKING PRODUCTS. In terms of Premier and Business banking products, customer support and documentation for these tailored banking services will generally only be available in English and/ or Afrikaans, given the complexity of certain unique products such as structured finance transactions available to these segments of the market. 7. EFFECTIVE DATES; DURATION AND REVIEW Upon the approval of the FNB language policy by the National Credit Regulator it will be implemented by FNB within 9 (nine) months from notification of approval 1. This document will be the governing document regulating FNB s language policy approach. The document will be revised every 2 (two) years to maintain a good standardized approach and based on consumer demographics. 1 FNB will require 9 months for system development 5
8. AVAILABILITY OF FNB S LANGUAGE PROPOSAL Upon the approval of the FNB language policy by the National Credit Regulator, consumers will be able to obtain a copy of this policy on www.fnb.co.za. 6